PTM113249 - International: UK tax charges on non UK schemes: the member payment charges and taxable property charges: overview of how the regulations attributing payments work from 6 April 2017
Glossary PTM000001
Regulations 4ZA to 4ZF The Pensions Schemes (Application of UK Provisions to Relevant Non-UK Schemes) Regulations 2006 - SI 2006/207
Whilst a member has UK funds (that is a UK tax-relieved fund, relevant transfer fund, or ring-fenced transfer fund) under a relevant non-UK scheme (RNUKS), any payment made to or in respect of that member will be referable to the member바카라 사이트™s UK funds.
From 6 April 2017, whilst any payment made to or in respect of a member is referable to a member바카라 사이트™s UK funds, not every payment will reduce a member바카라 사이트™s UK funds. Also from 6 April 2017 a member바카라 사이트™s UK funds may be reduced by certain crystallisation events.
The regulations start by setting out which payments and events will reduce a member바카라 사이트™s UK funds (regulation 4ZA).
Regulation 4ZB then describes the amount by which a member바카라 사이트™s UK funds will be reduced by the payment or event.
Regulation 4ZC sets out the order of attribution. That is which fund or funds a payment will be referable to regardless of whether or not that payment will reduce the member바카라 사이트™s UK funds. This regulation also sets how the member바카라 사이트™s UK funds will be reduced by a payment or crystallisation event. The order of attribution will depend on the nature of the payment or event.
Regulation 4ZD provides for the depletion (or reduction) of a member바카라 사이트™s UK funds to be reversed in certain circumstances. This is because when a member바카라 사이트™s UK funds are reduced due to a crystallisation event they in effect are given an upfront deduction before the scheme makes a payment. Regulation 4ZD is designed to ensure the tax rules operate fairly and as intended.
Regulation 4ZE provides for how a member바카라 사이트™s UK funds will be increased if HMRC repays an overseas transfer charge to the scheme manager.
Payments of scheme pension or drawdown pension will not reduce a member바카라 사이트™s UK funds as the funds should already have been reduced when the pension crystallised. However if the pension crystallised before 6 April 2017 the member바카라 사이트™s UK funds will not have been reduced by the crystallisation event. Regulation 4ZF makes provision for the treatment of drawdown pension and scheme pension payments made on or after 6 April 2017 in respect of pre-6 April 2017 crystallisations.
Detailed guidance on each provision can be found as shown below:
Payments that reduce a member바카라 사이트™s UK funds - see PTM113250.
Crystallisation events that reduce a member바카라 사이트™s UK funds - see PTM113255.
The order of attribution - see PTM113260.
When a member바카라 사이트™s UK funds will be increased - see PTM113265.
Examples - see PTM113270.